The following are comments/concerns pertaining to why the 4K Industrial Park barge dock facility does not benefit the public interest:

  • There should not be a meeting until all COVID-19 public gathering restrictions have been lifted. An online virtual hearing should not be an option, as many people in the surrounding community who stand to be most impacted by this facility are elderly and there is limited bandwidth in this area. Also, with the restrictions and social distancing orders in place, many folks will not be able to access the hearing because they do not have internet at home at all. They have no way of being adequately heard in this situation. Also, you should halt any further permitting on facilities until the COVID-19 restrictions are lifted. The US EPA has relaxed regulations and in many states there are no responses currently being done to environmental complaints. A new facility should absolutely not be permitted until the regulations are back to normal. I do not believe this facility is in the public’s best interest. Also, please do an Environmental Impact Statement on this facility as it could potentially impact the environment in multiple ways (some of which are listed below).

  • Possible accidents:The facility would be receiving fluids from the Gas and Oil markets for processing, to reuse the fluids for drilling operations or to be sent to a disposal facility. Fracking wastewater has been found to have dangerously high levels of radioactivity. If there is a leak or a spill or an accident such as a collision involving one of the barges at or near this facility, (or at any other point along the Ohio River, such as at the Pike Island Locks & Dam just 10 miles upriver or at any other Locks & Dam along the River) this could result in damage to the River, which is a drinking water source for about 5 million people. This also poses a threat to human health.

Justin Nobel info

Roxanne comments from letter

Comments from Terry Lively letter

  • Negative Impact to Economy: How would the local economy become impacted? There is virtually no benefit to the local economy if this facility would be constructed. The only people who would benefit would be the people making money off of the operations, such as 4K and the people they do business with. Concurrently, this would likely repel people from wanting to come to the area to live, work, and recreate. Who would want to live close to a facility that deals with this dangerous waste, especially if they knew all of the downsides to it? This will likely drive people away from the area and not be beneficial to the community in any way.

  • General leaks from normal operations: It is likely that there will be leaks and small spills that happen during normal operations that occur unintentionally throughout the process of loading and unloading and dealing with the waste. What would be the cumulative damage of these normal small leaks and spills and how does the agency and the company plan to minimize or prevent damage?

  • Drinking water concerns: If there is a leak or spill (whether the small, normal ones or large accidents) the waste could potentially contain dangerously high levels of radioactivity and toxic unknown proprietary chemicals. This could threaten the drinking water for the 5 million people who use the Ohio River as a drinking water source. Also, the heavy metals and high levels of salinity that are present within this waste could threaten drinking water. Even communities that draw their water from wells underneath or adjacent to the river could be impacted, as the river communicates with the wells.
  • Will there be other types of waste that could threaten drinking water as well - not just fracking fluid waste? How will we know what is in the barges and w4/hat will be tested? How will we know where the waste is being shipped to?

  • Lack of oversight in Ohio: ODNR oversees oil and gas waste processing facilities in Ohio.  Yet, ODNR has not developed any rules regulating frack waste processing facilities.  Instead, ODNR regulates these facilities by issuing ad hoc “Chief’s Orders.”  No public notice is required, no reporting by the facility is required.  This limits the public’s ability to understand facilities that are operating in their communities. Without clear and consistent regulations, how can the public trust that the facility is operating safely from day-to-day?  Expanding an under-regulated facility and enabling it to take additional frack waste for processing via a drinking water body is not in the public interest and presents serious risks for human health and the environment.

  • How will this project impact groundwater, particularly the groundwater that the surrounding community relies on for drinking water? Existing monitoring wells at the facility have shown concerning levels of radioactivity in the groundwater below the site.  How will increasing the amount of waste processed at the site, and transporting that waste from the river impact groundwater?  What is the travel time for any contamination of groundwater at the site to reach public drinking water well fields?

  • Impacts to air quality: There are open tanks at the 4K Industrial site currently. What are they holding? Is it radioactive? Is it laden with chemicals that can volatilize into the atmosphere and cause health impacts to the nearby community? How would the additional operations with the barging processes and filling/emptying the tanks, etc. cause additional impacts? There are concerns that as the tanks fill with the waste from the barges, chemicals and radioactivity would be released into the air. 

  • What would be the cumulative impact to the air when the barge loading/unloading operations are combined with the present operations?
  • Also, Rt. 7 is a heavily-traveled highway next to these operations. More diesel particulates are in the atmosphere from Gas & Oil trucks constantly on this highway. More traffic means more harmful particulate matter in the air.

  • Impact to local community/businesses: The population of Martins Ferry is only a few hundred feet away across the OH Route 7 highway. Also, the Martins Ferry High School football field is very close to the 4K Industrial water treatment facility.

  • Facility is having environmental problems currently: There should not be any permitting for expansion of a facility while the facility is having ongoing environmental problems (see inspection reports).

 

  • Harms to river wildlife: How would amphibians, fish, and other species living in the river be impacted by potential spills, leaks, and accidents?

  • Impact to fishing industry: Would the fishing industry become impacted if it was known that Oil & Gas wastewater was being transported along the Ohio River or if leaks or spills happened? There are many fishing tournaments that happen yearly along the Ohio River. Also, many people fish regularly along the river throughout the year. This happens locally in the Martins Ferry/Wheeling area as well.  

  • Other recreation along the Ohio River: How would this impact the boating industry and other people who use the river to recreate? If they knew what was in the barges and the harms associated, would they still use the Ohio River? What about the recreation businesses along the river? How would they become impacted? The Ohio River is already compromised - this would only make it worse. There is a raceboat regatta tournament that happens in Wheeling, just South of the facility each year.  How would the visitor and tourism industry be impacted?

  • Out-of-state waste: Much of the waste would likely be coming from out-of-state. Ohio is already a dumping ground for frack waste from other states, including PA and WV. Some states have stricter regulations for the radioactivity in oil and gas waste than Ohio’s regulations. The industry is capitalizing on this fact.  This facility could enable the transport of waste from more highly regulated states to Ohio, since Ohio’s regulations of radioactive materials in frack waste are extremely weak and makes it more economical to dispose of here than in other states.
  • What other states would this be coming from?
  • Will it come from up the Mississippi from shale fields in other regions?
  • Will there be other types of waste as well- not just fracking fluids?
  • Will we even be able to know what is in this waste and where it is coming from and where it is going to?
  • What kind of testing will be happening? Will they test each load for radioactivity and/or chemicals?

  •  Impact to scenery: How would this facility hurt the scenery of the area? Would this create a situation where people are repelled from coming to the area to live, work and play? How would this impact the area’s economy overall because of the aesthetic impact?

  • Mental health impacts: How would people react if they knew about this facility and the true risks? (The potential and real impacts to the air, water, land, and economy of the Ohio River Valley.) The facts of this operation, when known, could cause stress for people who live in the area.

  • Flooding: This facility is proposed to be built in a 100 year flood plain. U.S. Army Corps of Engineers have already stated in their 2017 study that flooding will likely increase as climate change continues to worsen and that “Climate change will push the Ohio River and its tributaries into uncharted waters, setting off economic and environmental crises like never before across a 13-state region.” (see link to newspaper article and study below) Floods in this area are more likely and could result in dispersion of toxic, radioactive materials washing onto the surrounding community (such as the Martins Ferry High School football field just a few hundred feet away). It could also mix in with the Ohio River and threaten drinking water that way. 4K Industrial already has wastewater recycling at the site with open containers, etc. Could these structures become impacted if floods reach that level?

  • Climate change impacts on barge traffic: USACE found in the same 2017 study that “More frequent and heavy droughts will likely dramatically reduce river volumes in some spots, putting in jeopardy drinking water supplies, barge traffic and power generation that relies on abundant water.” (study linked above)